QUESTION $4$

$(17$ marks$)$

Queen met Macg on a bus whilst travelling Europe. Both are young professionals. Queen is a South African resident and Macg is from Greece. They fell in love on this trip, kept in contact via Zoom and a year later decided to get married.

Queen is a family person and wants to stay in SA$.$ Macg is willing to move to SA but is worried about the tax implications if he immigrates to SA$.$

Macg prepared a summary of income and asked Queen to advise him on his tax affairs if he decides to make SA his permanent home. The summary consisted of the following:

Salary from Bank of Greece $-$ the Bank of Greece agreed that he can transfer to the SA branch and continue his normal duties in SA$.$

Royalty income $-$ Macg invented a micro chip in Greece which transfers money from one ATM to another when inserted into the ATM, this was the first of its kind in the world. A SA bank contacted him a few years ago to buy the patent rights to develop a similar chip in SA$.$ The SA bank pays the royalty once a year at the end of December.

Rental income from property in Malta $-$ Macg rents the property out to holidaymakers.

Dividend income $-$ Macg and his Dad owns a company in Greece that manufactures leather goods. Macg holds $51\%$ of the business shares and his dad the rest. Macg gets a yearly gross dividend of Euro $150000.$

Interest from long$-$term deposit account from the Bank of Greece. He has Euro $220000$ in the bank and he earns $1\mathrm{.}25\%$ interest per annum. Due to the economic crisis in Greece he wont be able to change the terms of this deposit and will have to leave Euro $200000$ in Greece.

$\backslash$table$[[$REQUIRED:$,$MARKS$],[\backslash$table$[[4\mathrm{.}1$ With regards to Note $2$ only, discuss the SA tax implications for Macg before$],[$he becomes a SA resident. Clearly state who is responsible and liable for$],[$tax$]],(3)],[\backslash$table$[[4\mathrm{.}2$ Discuss the SA tax implications of all receipts if Macg makes SA his$],[$permanent home after marrying Queen on $5$ January $2024$ in Cape Town.$],[$If a specific type of tax over and above normal income tax is applicable$],[$clearly state it$.]],(11)],[\backslash$table$[[4\mathrm{.}3$ Explain to Macg why, how and when he will need to register and pay$],[$provisional taxpayer$]],(3)]]$

ANNEXURES

AVERAGE AND SPOT RATES FOR CONVERSION.

$\backslash$table$[[$Average Exchange Rates are as follows:,US $\frac{\text{\$}}{R},\frac{1}{R}$